1. 1. Honesty and Fair Dealing

The Company’s reputation for integrity is tested every day by the way we treat customers, suppliers and each other. Honesty, fairness, and keeping commitments must be hallmarks of the way we do business:

1. 1. 1. Sell our products & services on their merits. Describe them truthfully and set reasonable expectations with our clients, clearly indicating the terms of delivery and payment. Customers should not be surprised by conditions that were not previously disclosed.
      2. Ensure that commitments are honored and that all our customers receive the highest quality service that we can provide.
      3. Portray the Company accurately. Statements should be sufficiently candid, clear, and complete so that they neither mislead nor lend themselves to misinterpretation. These criteria apply to all communications about the Company, including advertisements, reports to customers, sales literature, etc. Please note that all inquiries from analysts or the media are to be directed to the Company’s Chief Financial Officer.
   2. Data Accuracy

Financial information, employee files, and other corporate data should meet our primary standard, complete integrity. If you have responsibility for maintaining corporate data, utilize the following practices:

1. 1. 1. Make sure corporate records are scrupulously accurate, fully documented, and meet the highest standards of professional practice. Financial data should be complete and current, with all assets, funds, and liabilities fully and properly recorded.
      2. It is the responsibility of each employee to uphold these standards. Appropriate records must be kept of all transactions. Employees are expected to cooperate fully with our auditors.
      3. Information must not be falsified or concealed under any circumstances. Employees who are found to have engaged in false or misleading financial reporting will be subject to disciplinary action up to and including discharge.
      4. Report questionable accounting or auditing matters.
   2. Compliance with Laws and Regulations

You have a personal responsibility to become familiar and comply with the laws and regulations related to your job responsibilities. If you have any questions regarding these laws, you should seek advice from your supervisor or manager. If you have any concerns regarding the propriety or legality of any conduct or proposed course of action, you should immediately seek advice from your supervisor, a member of management or a member of the Company’s Executive Leadership Team. Alternatively, you may use the Ethics Hotline to report your concerns. Remember that violations of law are very serious. In addition to doing severe damage to the Company and its reputation, people who violate laws – including the antitrust and securities laws described below – are often fined and/or imprisoned

1. Executive Commitment to Ethics
   1. Senior leaders and executives within must set a prime example. In any business practice, honesty and integrity must be top priority for executives.
   2. Executives must have an open-door policy and welcome suggestions and concerns from employees. This will allow employees to feel comfortable discussing any issues and will alert executives to concerns within the work force.
   3. Executives must disclose any conflict of interests regard their position within.
2. Employee Commitment to Ethics
   1. Employees will treat everyone fairly, have mutual respect, promote a team environment and avoid the intent and appearance of unethical or compromising practices.
   2. Every employee needs to apply effort and intelligence in maintaining ethics value.
   3. Employees must disclose any conflict of interests regard their position within.
   4. Employees will help to increase customer and vendor satisfaction by providing quality product s and timely response to inquiries.
   5. Employees should consider the following questions to themselves when any behavior is questionable:
      1. Is the behavior legal?
      2. Does the behavior comply with all appropriate policies?
      3. Does the behavior reflect values and culture?
      4. Could the behavior adversely affect company stakeholders?
      5. Could the behavior adversely affect if all employees, did it?